TVT’s committee’s comments on the DRAFT Neighbourhood Plan

First of all we would like to thank the Forum for a very comprehensive document that covers all aspects and more in its proposals, however, The Village Trust does have a number of points to make.

Perhaps we can open by quoting from the Department for Communities & Local Government in their guide to neighbourhood Plans.

A Neighbourhood Plan is about the uses and development of land. It should not promote less development than that identified in the development plan for the local area.

Often the process of preparing a plan will highlight non- planning issues.

These would not form part of the statutory neighbourhood plan so should not be subject to the independent examination and referendum.

Wider community aspirations than those relating to development and use of land can be included in a neighbourhood plan, but actions dealing with non land use matters should be clearly identifiable. For example, set out in a companion document or annex

A neighbourhood plan may deal with transport insofar as it relates to new development. It may not deal with things like traffic management of existing networks, unless such management would be necessary to allow development to be approved.

Taking these guidelines into consideration it would appear that Chapters 10 (Getting Around), 12 (The Built and Natural Environment), and 13 (Historic Titchfield) fall outside the plans remit, and certainly outside the referendums terms of reference.

Concentrating then on the planning and development.

Our major concern is over paragraph 9.3. This paraphrases the report you commissioned from AECOM which arrived at a figure of 262 dwellings to be built within the Neighbourhood Plan area. Taking into account the Coach and Horses site, The Mitie site, The East St Garage site and the 86 dwellings on the retirement village site off Cartwright Drive this would leave 153 dwellings to be built within the plan period of 16 years. You also state this in your summary para 1.2 “During the lifetime of the plan an average of 10 dwellings a year will be needed”

One does need to raise the question if 10 aren’t built in year 1 does that mean 20 in year 2 etc.etc. until you reach 153 ?

We do note that you state in para 9.6 you are not specifying any sites within this plan.

If these paragraphs remain in the plan they will, if the referendum votes yes, form a central part of the local plan that affects Titchfield and we are certain that developers will notice this and they, as they are already doing, will inevitably identify sites.

As things stand within the current draft local plan Fareham has “NO development” planned for Titchfield. You even quote their 2036 plan “Titchfield is a small settlement, with a rich historic character and a thriving local centre. Few development opportunities have been identified, apart from small infilling proposals”

You also quote their own Core strategy and Policy CS22 which creates the strategic Meon Gap, which means that proposals for development will not be permitted.

If you are proposing “no development” then surely there is no necessity to hold a referendum on something that is already being proposed by FBC.

At the moment the National Planning Policy Framework states :

Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. Within this overall requirement, strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations

Once the strategic policies have been adopted, these figures should not need retesting at the neighbourhood plan examination, unless there has been a significant change in circumstances that affects the requirement

Fareham have already decided no development within the Neighbourhood Plan area but have been told by the government they will have to increase their current allocation. The Village Trust Committee do not believe that they should, or in fact will, go back on their commitment to Titchfield. You do, however, seem to be saying there needs to be development.

A few other points outside the referendum agenda but included in the Plan:

Para 4.2 :

It was the Village Trust that asked the Neighbourhood Forum to cease being a sub-committee. Fareham Borough Council, were asking us to alter our constitution in order to fit the Neighbourhood Forum regulations. We felt, more than anything else, we had to remain independent from both local and national government so asked the Forum to leave and go their own way.

Para 10.6

“The growth of car ownership has not been offset by any significant increase in parking facilities”

We helped campaign for the new parking arrangements in the community centre after 2 traffic surveys carried out by FBC resulting in an extra 30 spaces, this would seem to us ‘significant’

Para 13.5

”In later years, the Barn was again abandoned and was acquired by FBC in conjunction with the surrounding land”

No. The Barn was owned by Millan Mandaric Holdings and was first leased to The Titchfield Festival Theatre and then sold to them.

The surrounding land, now the new country park, was given to FBC as a gift, being part of the Retirement Village development deal. Something the Village Trust were involved with, and helped bring to fruition, from the start.

The following is the response by the Forum to the Titchfield Village Trust document.

Summary.

• The TVT document does not necessarily reflect the views of all the members of the Trust. At least 16 members of the Forum are Trust members and we have always acknowledged that this project arose from a TVT initiative. The original intention was for the Trust to guide the project.

• The DRAFT Neighbourhood Plan (NP) is not an open door to developers – just the reverse

• The Neighbourhood Plan does not identify any sites because none meet the criteria for the policies.

The Housing group researched all potentially available land in the NP area which included all the sites submitted to FBC under their Call for Land process. These could have produced over 1000 dwellings in the NP area.

• The Neighbourhood Plan does not support development unless the development meets the policies set out in that Plan. Hence no sites are proposed in the NP.

• Many of the NP policies are largely similar to the ones supported by the Trust.

• Fareham Borough Council are now working alongside the Forum. Their aim, like ours, is for no sites in this area.

• For the FBC Planning Department and Executive the successful Plan will give them more democratic backing if pushed to increase their housing development intentions.

General comments on the TVT document

With every policy there must be background. It is no good expecting an independent examiner to picture an area and its development without a clear idea and understanding of that Plan area. The Plan policies are also based on this background information regarding the conservation and setting.

The conservation area is a key factor in the background to planning decisions in this area which is why we consulted Historic England on what should be in that particular section. We received very sound advice from them on the wording of policies in this area. As one of the key bodies with whom we have consulted it would be foolish to omit what they say.

Environmental issues have to be clearly stated as they set the scene. This was one of the criteria for assessing sites and has formed a part of our appeal statement against the Posbrook site.

Traffic and the Neighbourhood Plan. TVT is correct that traffic policies are not statutory policies unless there is a planning issue. However, non-land use planning proposals can be included as community aspirations or projects. These are sometimes included in a separate section or in our case in a coloured box with a clear insert that these are community aspirations. Although not legally enforceable having them all in one place in the Neighbourhood Plan can help focus the community’s efforts on realising the projects and therefore may help deliver them more quickly. It is also important that the present traffic conditions are clear as accessibility is one of the key reasons for sites to be deemed unsuitable.

Community consultation. Through emails, website posts, meetings, articles and letters, the community has raised many issues. These issues, although not developmental issues are important to the community and should be recorded as aspirations or concerns. As the Forum closes after the referendum it may be good to reflect on some of these issues for further work. Instead of looking back at what has been done, looking forward to what could be done would be pivotal to achieving success. These will be in the Plan document and will give added residents’ weight to further community action, especially on traffic.

For the FBC Planning Department and Executive, the successful Plan will give them more democratic backing if pushed to increase their housing development intentions.

The money the Forum has received from National Government plus very welcome contributions from members of the public and businesses was for fees for consultants, printing, publicity and room hire. Also, very importantly, public liability insurance enabled everyone to be covered at the open meetings as well as when the flyers were being delivered or presentations made to local groups.

Achieving sustainable development

Extract from Locality Neighbourhood Plans Road Map Guide p.30 (note: Locality is the organisation charged by the Government to support Neighbourhood Forums)

‘Neighbourhood plans must contribute to achieving sustainable development. The Government’s approach to sustainable development is set out in the National Planning Policy Framework. Essentially, it is about enabling growth to cater for the needs of current generations but ensuring that growth doesn’t mean worse lives for future generations. There are many ways in which a neighbourhood plan can address sustainable development. Some practical examples are:

• encouraging and requiring mixed transport provision, including accessible public transport,
cycle facilities and safe and convenient pedestrian routes;
• encouraging mixed-use areas, thereby reducing the need for travel;
• ensuring a good mix of community facilities in the area;
• encouraging facilities to support and encourage home working, including fast broadband;
• requiring good urban design, creating safe, attractive, convenient, well-connected streets
and spaces;
• ensuring new development enhances the viability of city, town, village and local centres;
• enabling provision of varied local employment opportunities;
• requiring provision of a good mix of housing of different sizes to meet local need;
• considering the protection and enhancement of the natural environment including wildlife
areas and high-quality landscapes;
• encouraging and enabling the reuse and refurbishment of existing buildings;
• encouraging green development and local energy generation;
• prioritising brownfield sites;
• conserving historic buildings and areas and ensuring they remain in productive use and
realise their potential.

These are just a few examples, but they give a flavour to the diverse ways in which sustainability can be addressed. Things like energy efficient construction are largely covered by building regulations, but may be encouraged by the neighbourhood plan, for example by welcoming innovative design solutions.’

Housing

The Housing need is 153 dwellings net over the lifetime of the Plan up to 2036. Any new development will need to meet the policies in the NP which are not so different from those of the Trust, ie respecting the Strategic Gap and the heritage of the area.

The Neighbourhood Plan supports the core Local Plan policy of redeveloping already developed – i.e. (Brownfield) sites – an example being the three dwellings built on the Titchfield Motors site.

New National Planning Guidance means that new Neighbourhood Plans will have to make provision for housing. This is not currently the case and it is important that the Neighbourhood Plan is approved therefore before the 24th Jan 2019 when this new guidance comes into effect.

Conclusion:

It is sad that TVT has not felt able to work with the Forum on the Plan. We are two groups who both care for their area. Let us hope that everyone will be able to work better together in the future.